Abusive tax shelter definition

Abusive tax shelter means any partnership, corporation or other organization or entity, any investment plan or arrangement or any other plan or arrangement, which has as its principal purpose the evasion or improper avoidance of federal or state income tax. “Abusive tax shelter” includes any investment or activity in connection with which tax benefits derived by investors are not clearly intended under the tax laws or any investment or activity that involves little or no economic reality, making use of unrealistic allocations of income or expenses, inflated appraisals of asset values, losses substantially in excess of investment, mismatching of income and expenses, financing techniques that do not conform to standard commercial business practice or mischaracterization of the substance of the investment or activity.
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Abusive tax shelter means any scheme the principal purpose of which is to evade or underreport
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Abusive tax shelter means any scheme the principal purpose of which is to evade or underreport Montana or federal income taxes and includes:
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Related to Abusive tax shelter

  • Animal shelter means a facility operated by a humane society or any society organized under Chapter 1717. of the Revised Code or a dog pound operated pursuant to Chapter 955. of the Revised Code.

  • Income Tax Act means the Income Tax Act (Canada), as amended from time to time;

  • Homeless shelter means a facility providing temporary housing and services for homeless persons.

  • Non-U.S. Tax Person A person other than a U.S. Tax Person.

  • Income Tax Return means any Tax Return relating to Income Taxes.

  • U.S. Tax Person means a Person that is a “United States person” as defined in Section 7701(a)(30) of the Code, generally including:

  • Applicable Tax Law means any Applicable Law relating to Taxes, including regulations and other official pronouncements of any Governmental Entity or political subdivision of such jurisdiction charged with interpreting such Applicable Law.

  • Sexually violent predator means a person who:

  • Income Tax Returns means all Tax Returns relating to Income Taxes.

  • Undervote means that the elector does not properly designate any choice for an office or ballot question, and the tabulator records no vote for the office or question.

  • Applicable Tax State means, as of any date, (i) any State in which the Owner Trustee maintains the Corporate Trust Office, (ii) any State in which the Owner Trustee maintains its principal executive offices and (iii) any State in which the Servicer regularly conducts servicing and collection activities (other than purely ministerial activities) with respect to a material portion of the Receivables.

  • Sexually violent offense means an offense for which a conviction has been entered for any of the following indictable offenses:

  • Non-United States Tax Person Any Person other than a United States Tax Person.

  • Violent offense means a violent offense as defined in RCW 9.94A.030;

  • Nonviolent offense means an offense which is not a violent

  • Intimidating, threatening, abusive, or harming conduct means, but is not limited to, conduct that does the following:

  • fradulent practice means a misrepresentation or omission of facts in order to influence a procurement process or the execution of contract;

  • Straddle Tax Period means a Tax period that begins on or before the Closing Date and ends thereafter.

  • Disqualified Non-United States Tax Person With respect to any Class R Certificate, any Non-United States Tax Person or agent thereof other than: (1) a Non-United States Tax Person that (a) holds such Class R Certificate and, for purposes of Treasury Regulations Section 1.860G-3(a)(3), is subject to tax under Section 882 of the Code, (b) certifies that it understands that, for purposes of Treasury Regulations Section 1.860E-1(c)(4)(ii), as a holder of such Class R Certificate for United States federal income tax purposes, it may incur tax liabilities in excess of any cash flows generated by such Class R Certificate and intends to pay taxes associated with holding such Class R Certificate, and (c) has furnished the Transferor, the Trustee, the Certificate Administrator and the Tax Administrator with an effective IRS Form W-8ECI or successor form and has agreed to update such form as required under the applicable Treasury regulations; or (2) a Non-United States Tax Person that has delivered to the Transferor, the Trustee, the Certificate Administrator and the Tax Administrator an opinion of nationally recognized tax counsel to the effect that (x) the Transfer of such Class R Certificate to it is in accordance with the requirements of the Code and the regulations promulgated thereunder and (y) such Transfer of such Class R Certificate will not be disregarded for United States federal income tax purposes.

  • Transparent copy of the Document means a machine-readable copy, represented in a format whose specification is available to the general public, that is suitable for revising the document straightforwardly with generic text editors or (for images com- posed of pixels) generic paint programs or (for drawings) some widely available drawing editor, and that is suitable for input to text formatters or for automatic translation to a variety of formats suitable for input to text formatters. A copy made in an otherwise Transparent file format whose markup, or absence of markup, has been arranged to thwart or discourage subsequent modification by readers is not Transparent. An image format is not Transparent if used for any substantial amount of text. A copy that is not “Transparent” is called “Opaque”.

  • Payroll Tax Executive Order means the Presidential Memorandum on Deferring Payroll Tax Obligations in Light of the Ongoing COVID-19 Disaster, as issued on August 8, 2020 and including any administrative or other guidance published with respect thereto by any Governmental Authority (including IRS Notice 2020-65).

  • Foreign person means any person (including any individual, partnership, corporation, or other form of association) other than a United States person.

  • Small disadvantaged business concern means a small business concern that represents, as part of its offer that—

  • Violent student means a student under the age of 21 who:

  • Violent felony means the same as that term is defined in Section 76-3-203.5.

  • United States Tax Person A citizen or resident of the United States, a corporation, partnership or other entity created or organized in, or under the laws of, the United States, any State thereof or the District of Columbia, an estate whose income from sources without the United States is includible in gross income for United States federal income tax purposes regardless of its source or a trust if a court within the United States is able to exercise primary supervision over the administration of the trust and one or more United States Tax Persons have the authority to control all substantial decisions of the trust, all within the meaning of Section 7701(a)(30) of the Code (or, to the extent provided in the applicable Treasury Regulations, certain trusts in existence on August 20, 1996 that have elected to be treated as United States Tax Persons).